Frequently Asked Questions About Fitness-for-Duty (FFD) Programs for Construction
This section provides the NRC staff's answers to the following questions related to FFD programs for construction, as it relates to fitness-for-duty:
Our company builds power plants. Do the FFD regulations apply to the workers involved in the actual construction of the plant?
Yes, 10 CFR 26.4(e) and (f) specify the individuals involved in nuclear power plant construction who must be subject to a fitness-for-duty program.
Does a Combined License (i.e. COL) applicant, which does not rely on NEI 06-06 for the description of its FFD program during construction, need to explain in its application any differences between its description of its FFD program during construction and NEI 06-06?
If the applicant does not rely on NEI 06-06, the applicant does not have to explain differences between its program and the one described in NEI 06-06. A COL applicant's operational programs, such as FFD, must be "clearly and sufficiently described in terms of the scope and level of detail to allow a reasonable assurance finding of acceptability. Required programs should always be described at a functional level and at an increased level of detail where implementation choices could materially and negatively affect the program effectiveness and acceptability." See the Commission's Staff Requirements Memorandum for SECY-04-0032.